United States v. Miguel Gonzalez Segovia
20-3028
| 3rd Cir. | Jun 11, 2021Background
- Trooper John Stepanski stopped Miguel Gonzalez Segovia on I‑78 after observing him follow a commercial truck allegedly too closely and after Gonzalez Segovia delayed pulling over and briefly stopped on a bridge.
- On the roadside Gonzalez Segovia appeared extremely nervous, gave inconsistent travel answers (said coming from California, passing through Ohio, headed to “Brooklyn” after saying New Jersey), lacked a destination address, and had six large suitcases in a rented Ford Expedition due back the next day.
- Stepanski ran license/plate checks, called for backup, and continued questioning beyond routine traffic inquiry before deciding to search the vehicle.
- Stepanski obtained verbal permission and had Gonzalez Segovia sign a summarized consent/waiver form; the search revealed kilogram‑sized packages of cocaine/fentanyl in a suitcase.
- Gonzalez Segovia pleaded guilty while reserving the right to appeal the denial of his motion to suppress; the District Court denied suppression and the Third Circuit affirmed.
Issues
| Issue | Gonzalez Segovia's Argument | Government/Trooper's Argument | Held |
|---|---|---|---|
| Lawfulness of initial stop | No reasonable suspicion to stop for following too closely | Officer reasonably observed a traffic violation (too close) | Stop lawful — reasonable officer could justify stop for following too closely |
| Whether the stop was unlawfully extended | Officer turned routine questioning into a fishing expedition and prolonged the stop without reasonable suspicion | Initial travel questions were traffic‑related; extension justified once facts generated reasonable suspicion | Measurable extension occurred but was justified by reasonable suspicion (delayed pull‑over, nervousness, inconsistent answers, excess luggage) |
| Validity of consent to search | Consent was coerced/defective (quick/animated delivery, trooper walked away, form not read verbatim, possible language confusion, officer near firearm) | Consent was voluntary under the totality; trooper summarized waiver and informed of right to refuse; defendant fluent in English | Consent valid under totality of circumstances; District Court's finding not clearly erroneous |
Key Cases Cited
- United States v. Green, 897 F.3d 173 (3d Cir. 2018) (reasonable suspicion for traffic stops)
- United States v. Yusuf, 993 F.3d 167 (3d Cir. 2021) (focus on objective basis for stops)
- United States v. Wilson, 960 F.3d 136 (3d Cir. 2020) (pretext is irrelevant to stop legality)
- Rodriguez v. United States, 575 U.S. 348 (U.S. 2015) (stop may not be extended beyond traffic mission without reasonable suspicion)
- United States v. Garner, 961 F.3d 264 (3d Cir. 2020) (standards of review; viewing facts in government's favor after denial)
- United States v. Bey, 911 F.3d 139 (3d Cir. 2018) (limited investigative detention to test reasonable suspicion)
- United States v. Stabile, 633 F.3d 219 (3d Cir. 2011) (totality of circumstances test for consent)
- United States v. Williams, 898 F.3d 323 (3d Cir. 2018) (factors relevant to voluntariness of consent)